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TrendVectorAviation International, Inc. 

17-3404 Neptune Ave. 

Barrigada, Guam 96913 U.S.A. 

Tel {671)473-4100 Fax (671)473-4101 

http://www.trendvector.com 

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U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor -

Room W12-140 

1200 New Jersey Avenue, SE. •" - .;: 

Washington, DC 20590 " 

TrendVectorAviation International, Inc. (TVAI) is petitioning the Federal Aviation 

Administration (FAA) for a one time exemption from § 141.5(e) of Title 14, Code of Federal 

Regulations (14 CFR). Part 141.5(e). Part 141.5(e) provides, that the FAA may issue a 

pilot school certificate with the appropriate ratings if, within the 24 calendar months before 

the application is made, the applicant has graduated at least 10 different people from the 

school's approved training course. 

TVAI has not been able to renew its pilot school certificate because we have graduated 

fewer than 10 different students over the 24-month period preceding expiration of its 

Provisional Pilot School Certificate. TVAI has graduated three students and currently has 

eight students enrolled in the private pilot certification and instrument rating courses. We 

expect these students to complete their training within tw/elve months 

TVAI contends that there is no provision in § 141.5 that permits a pilot school who is 

providing training to a smaller segment of general aviation, to reduce the required number 

of graduates needed to qualify for renewal of a pilot school certificate. TVAI asserts that it is 

not in the best interest of the public to deny renewal of a Part 141 Provisional Pilot School 

that operates on a small island in the Western Pacific, who may not train enough students 

under Part § 141.5. Instruction under Part 141 can offer a higher level of knowledge and 

experience in a more disciplined pilot school training program. The stringent requirements 

imposed by part 141 for course approvals and the conduct of training will ensure a level of 

safety equivalent to, or higher than, the training that would be conducted under part 61. 

There is public interest in the promotion of a Part 141 facility on the island of Guam. Our 

military clients are very interested in us achieving VA-approved status, which will allow for 

the use of Gl-Bill funds for military pilots pursuing advanced flight certificates. VA-approval 
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is dependent on the addition of a commercial pilot certification course to our school. 

Materials for that were provided with our renewal request form and discussions will 

continue once the current issue is resolved. 

Additionally, we are in the process of applying for the SEVIS program with the US State 

Department. This will allow us to issue student visas to flight students visiting us from 

abroad. We are in talks with a number of Asian-based airlines regarding cadet pilot 

training. Should we be successful in these ventures, we expect to bring economic benefit 

to the island as these students will be here for potentially several months, and may 

potentially bring their families with them. Membership in the SEVIS program is dependent 

on being a Part 141 school. 

With the planed military buildup on the two bases on Guam, and no Aero Club, military 

members have no other alternatives for training. 

TVAI believes this one-time relief from the requirements of 14 CFR §141.5(e) will be 

sufficient for us to move forward with a successful and productive Part 141 flight school, the 

only one of its kind in the Western Pacific. With the recent addition of CATs testing 

on-island, the addition of the Commercial Pilot Certification course option, the continued 

expansion of the military presence on island, subsequent VA approval of our flight school, 

and other commercial expansion planned by TVAI, we anticipate no issues meeting the 

requirements of 14 CFR §141.5 when subsequent renewal of our certificate in the future. 

With kind regards. 

Toshihiro Shima 

President 

Trendvector Aviation International, Inc. 

Email: shima@trendvector.com